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Facts:
Held:
The provisions of section 11 deal with the exemption of the total income of a ‘person’ who derives income from property held under trust for charitable or religious purposes. The plain reading of the definition of person also includes a company. The word institution is also not defined anywhere in section 12AA, but the meaning as given in Oxford Dictionary nowhere suggests that company is not an institution. The company being a person in accordance with the scheme of the Act is entitled to benefit of section 12A.
Thus the test whether an assessee could be registered u/s.12A is not the status of the ‘person’, but on the basis that whether the person (assessee) was established for charitable or religious purpose.
